Spouses Efren N. Rigor v. Consolidated Orix Leasing

Summary

This case involved conflicting venue provisions between a promissory note and its securing chattel mortgage deed. Spouses Rigor borrowed P1.6 million from Consolidated Orix, secured by chattel mortgage on dump trucks. When they defaulted, Orix filed replevin in Dagupan City where it had a branch office, but the Rigors claimed exclusive venue should be in Makati City per the promissory note. The Supreme Court held that as principal and accessory contracts, both documents must be interpreted together under Article 1374 of the Civil Code. The chattel mortgage's venue provision validly modified the promissory note's restrictive clause, allowing alternative venues including where the mortgagee has branch offices. The Court emphasized that venue rules serve convenience and justice, and Dagupan was more practical for both parties. This decision established the principle that accessory contracts like chattel mortgages must be construed together with their principal obligations, and that venue provisions in security instruments can modify those in the principal contract.